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Why We Need More than Common Sense Safety for Natural Gas Pipe System Cleaning and Purging Operations

Posted by Shivi Kakar

Jul 20, 2010 2:22:39 AM

By Don Hoeschele, MS, CHMM

The U.S. Chemical Safety Board (CSB) recently approved recommendations to the Occupational Safety and Health Administration (OSHA), the National Fire Protection Association (NFPA) and other organizations to help prevent explosions and fires during pipe cleaning and purging operations.  As recently as February 7, 2010 at the Kleen Energy power plant in Middletown, CT, an explosion caused six fatalities and numerous injuries during the cleaning of a natural gas pipe system. Another similar explosion occurred at the ConAgra Foods Slim Jim plant in Garner, NC on June 9, 2009 and caused the death of four workers. In both instances, an operation termed “natural gas blow” was utilized to force natural gas under pressure through a piping system during construction and prior to startup of the plant’s turbines to rid the pipe system of non-natural gas impurities and debris. The gas was vented to the ambient atmosphere at open pipe ends less than 20 feet from the ground, and in worker areas where the gas easily found a source of ignition.  It seems that common sense would lead one to never vent natural gas near sources of ignition.

  • At Kleen Energy the potential ignition sources included electrical power to the building, welders actively working and diesel-fueled heaters running in the vicinity.

  • Approximately TWO MILLION cubic feet of natural gas were released at Kleen Energy on February 7, 2010 during the “natural gas blow”, enough natural gas, according to the CSB, to provide heating and cooking fuel to the average American home every day for more than 25 years.


The CSB determined that no specific federal workplace safety standard exists that would prohibit the intentional release of natural gas into the workplace. Yes, I was shocked when I read that, too! Eighteen urgent recommendations were provided and voted on by the CSB to prevent future disasters. Some of the recommendations include – Prohibiting the use of natural gas for pipe cleaning and using alternatives such as compressed air, steam and other chemical substitutes, and upgrading the current gas safety standards for general industry and construction that are considered by the CSB to contain “significant gaps” that threaten the safety of workers at such facilities.

In February 2010, the CSB issued a safety bulletin titled “ Seven Key Lessons to Prevent Worker Deaths During Hot Work In and Around Tanks”.  This bulletin highlights another gap in the OSHA standards, “While the OSHA standard prohibits hot work in an explosive atmosphere, it does not explicitly require the use of a combustible gas detector”. 

It is an unfortunate fact that such regulatory “gaps” can be found in many industries. We are reminded of these gaps while reading of disasters such as these, or more currently, watching the daily updates of oil washing ashore in the Gulf of Mexico.  It is certainly welcome news that these CSB draft recommendations were quickly approved without amendments to help prevent future explosions during pipe cleaning operations.

Do you know of other examples of what would seem to be ‘common sense’ safety measures that are not utilized because “this is the way we have always done it” wins over common sense?
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Topics: OSHA, health and safety, General Industry H&S, Emergency Response, Chemical Safety Board, Hazardous Materials, Compliance, worker safety, emergency response training, Fire Safety, NFPA

Best Available Technology for Community Air Monitoring at Hazardous Waste Clean-up Sites

Posted by Shivi Kakar

Jul 12, 2010 7:57:55 AM



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Topics: OSHA, indoor air quality, Personal Protective Equipment, health and safety, Construction H&S, EPA, Hazardous Waste Management, Hazardous Materials, Compliance, worker safety, Occupational Health, Occupational Safety, Air Sampling, environmental air monitoring, Respiratory, Public Safety

Safety & Health Training – A Victim of Its Own Success?

Posted by Shivi Kakar

Jun 14, 2010 1:11:20 AM

Capt. John DeFillippo, CHMP, EMT-B

These are tough economic times and businesses are looking to cut costs and save money. A disturbing trend I have noticed is the willingness of many companies to make cuts in safety programs and employee training in a misguided attempt to improve the bottom line.

Trained workers are safer workers.  The facts bear this out. Shortsighted statements I’ve heard include; “We don’t have problems in that area, so we’re cutting back on training.”, when the training was most likely the reason for the lack of problems.

Often, it is difficult to see how beneficial training can be until you experience the effects of its absence. Negative indications show themselves in higher EMRs, increased workman’s compensation claims, lost production time, and property damage. Only companies actively tracking and trending incidents are likely to realize this. (By the way, such companies would also be the ones least likely to make such cuts in the first place!)

It takes just one serious incident resulting in injuries to quickly eliminate any savings associated with cutting programs and training.  What’s more, most health and safety training is required by regulations, so there is also the risk of fines for non-compliance. These can be hefty and since most companies don’t budget for them, they become an extraordinary cost – right off the bottom line!

At Emilcott, we have seen firsthand the effects that result from a lack of training.  Recently, we were hired by a client who laid-off their safety director a couple years prior.  After starting our work, we informed the client of numerous safety violations throughout their organization. These appeared to be a direct result of the lapse in proper safety training – since they no longer had a safety director to oversee their program.  Through the Emilcott Training Institute, our client was able to receive the training needed to avoid these safety violations – and keep their employees safe and on the job. However, in their attempt to save money, the client ended up spending more in a short period of time just to catch up.

Making drastic H&S budget cuts just never pay off.  As experienced health and safety consultants, we work with our clients to offer solutions when budgets get tight:

  • Outsource until you can hire again – we have provided EHS professionals at our clients’ sites for just this purpose for both short and long term requirements.

  • Prioritize your H&S needs – consider the total reduction in your workforce or operations to determine where you can pull back and where you cannot.

  • Take advantage of training courses open to the public – it may no longer be economically sound to run a training course in-house, but don’t lapse on required courses.

  • Take advantage of FREE resources – many consultants provide lots of free info and OSHA will provide all types of assistance at no cost. As an example, Emicott offers a comprehensive Free Training Needs Assessment at www.emilcott.com!

  • Pool resources – look toward your industry’s professional organizations or neighboring companies to share services. Maybe a part-time Safety Director is better than none at all.

  • Ask a professional – put together a plan and a program to get you through the lean times


Has your company adjusted their health and safety program for leaner times?

Have you seen a direct effect and how are you compensating?
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Topics: OSHA, health and safety, General Industry H&S, Construction H&S, Emergency Response, H&S Training, Compliance, worker safety, Occupational Health, Occupational Safety, Fire Safety, Occupational Training, Lab Safety, Safety Training in Spanish

Choosing the Correct High Visibility Clothing for Roadway Worker Safety

Posted by Shivi Kakar

Jun 7, 2010 8:52:43 AM

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Topics: DOT, Personal Protective Equipment, Construction H&S, Emergency Response, worker safety, Occupational Safety

Water Safety at Work

Posted by Shivi Kakar

May 24, 2010 2:57:16 AM

Capt. John DeFillippo, CHMP, EMT-B

Does your company have employees that work on, near or over water? Hazardous waste site and emergency response workers, those in the construction trades, surveyors and bridge inspection/repair crews are but a few occupations where this applies. OSHA regulations (29 CFR 1926.106 for example) cover the safety of such workers including training and protective equipment requirements. Other federal and state (USCG and TSA) regulations may also apply to your operation. For example, if you are working over water, such as bridge work, you must have a rescue skiff at the ready, with trained personnel to operate it, in case someone falls in. Working at piers, refineries or other marine facilities may entail very specific security requirements.

Water can be unforgiving of carelessness. As a veteran of the U.S. Coast Guard, an EMT and a licensed captain working in the marine salvage industry, I’ve seen plenty of tragedies on the water. Nearly all were avoidable. Here are some essential questions to help you assess your water safety knowledge:

  • Is everyone wearing personal flotation devices? Are they the right type, worn correctly, and U.S. Coast Guard approved?

  • What is the water temperature? In April in the mid-Atlantic region, the water is about 45 degrees F which means you can last about 15 minutes before hypothermia sets in.

  • Do you understand the risk of hypothermia? Even if the water is at 80 degrees F, it’s the same as being in air of 42 degrees F. And, water removes heat from the body 25 times faster than air of the same temperature.

  • Does everybody know how to swim? What to do if caught in a current? Will they know to swim parallel to the shore or go with it until you out of it? You can't swim against a current, even a gentle one, for very long, so don’t try.

  • If someone does fall in, what’s the plan? Formulating a plan when you hear the splash is too late! Having the proper rescue equipment and understanding how to use it is essential.

  • Who is trained in CPR and Basic First Aid? Knowing what to do in an emergency saves lives! Too many would-be rescuers become victims themselves, so leave water rescue to those who have the training and tools.

  • Is the boat operator trained? Employers who would never think of allowing an untrained person to operate a crane often have no problem letting someone without proper training operate a boat on a navigable waterway. Many states, including New Jersey, now require all operators of power-driven vessels to take an approved Safe Boating Course. Fines can be steep and may get the vessel impounded.


The Emilcott Training Institute offers many training programs that can help keep workers safe, including an 8-hour Water Safety and Boating Basics that is approved by the NJ State Police and recognized in several other states as well. Fall Protection, Water Safety and Red Cross CPR and Basic First Aid are also offered in-house or on-site. If you have ANY questions about water safety at work, give Emilcott a call or comment below.
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Topics: OSHA, Personal Protective Equipment, health and safety, General Industry H&S, Construction H&S, Emergency Response, H&S Training, worker safety, Occupational Safety, emergency response training, Occupational Training, water safety, Water Response Plan

Occupational Lyme Disease

Posted by Shivi Kakar

May 10, 2010 2:36:10 AM


<a href="ht tp://ehswire.com/writers/">John DeFillippo, CHMP
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Topics: health and safety, General Industry H&S, Construction H&S, worker safety, Occupational Health, Public Safety

Learning from H1N1 – Employers Need to Consider Continued Pandemic Threats

Posted by Shivi Kakar

May 3, 2010 4:48:24 AM

Genya Mallach - CSP
Most recently, we have had to educate ourselves on the wide-spread outbreak of influenza virus, H1N1, and the precautions necessary to break the pandemic, which is far from over. Not to downplay the risk of the H1N1 virus, a virulent, drug resistant form of Tuberculosis (TB) has appeared in the United States. This disease is so ancient that it has been found in the spine of a 4,400-year-old Egyptian mummy. Tuberculosis is still the top single infectious killer of adults worldwide. According to the World Health Organization, it lies dormant in one out of three people. Of those, 10 percent will develop active TB, and about 2 million people a year will die from it.

It was just six months ago that word was leaked to the public of a case of TB that was originally diagnosed in 2007, and has greatly alarmed the medical community. Oswaldo Juarez, a then 19-year old Peruvian visiting US to study English was diagnosed with XXDR (Extremely Drug Resistant) TB. This is a strain of TB that had never before been seen in the U.S.

Dr. David Ashkin, one of the nation’s leading experts on tuberculosis, described this form of tuberculosis as so rare that only a handful of people in the world are thought to have had it.The treatment of an XXDR TB is an equivalent to aggressive chemotherapy, requires strict quarantine and costs hundreds of thousands of dollars to treat.

The questions we must now ask are: Should we consider testing of TB in the work environment? Should periodic testing of all workers be required? Should we be worried of another pandemic?
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Topics: indoor air quality, health and safety, General Industry H&S, Emergency Response, H&S Training, worker safety, Occupational Health, emergency response training, Exposure, hygiene standard

What is a Certified Industrial Hygienist?

Posted by Shivi Kakar

Apr 23, 2010 5:47:54 AM

Sarah Stibbe Damaskos
Where were you the first time that someone casually mentioned that they were a Certified Industrial Hygienist? Chances are you immediately pictured some type of space-suited dental hygienist flossing the world’s most horrific tooth grunge.  Or maybe you heard the term “industrial hygiene” and the frightening image of super-sized Teflon underwear floated into your head?  The good news is that you were almost right – conceptually.

Certified Industrial Hygienists (“CIH”) are cool. Sometimes they do get to wear Major Tom kind of protective clothing and poke around dirty places but most of the time they’re more like a squad of Super Safety People and their goal is to protect you.  According to the American Board of Industrial Hygiene (www.ABIH.org) “Industrial hygiene is the science of protecting and enhancing the health and safety of people at work and in their communities.” 

Industrial hygienists (rather than be called Super Safety People which is so much better for T-shirts) fall into a large group more commonly known as Environmental, Health and Safety experts but CIH focus exclusively on Health – Occupational Health and Environmental Health.

The American Industrial Hygiene Association (www.AIHA.org) has created this handy list of typical EHS roles: 

  • Investigate and examine the workplace for hazards and potential dangers

  • Make recommendations on improving the safety of workers and the surrounding community

  • Conduct scientific research to provide data on possible harmful conditions in the workplace

  • Develop techniques to anticipate and control potentially dangerous situations in the workplace and the community

  • Train and educate the community about job-related risks

  • Advise government officials and participating in the development of regulations to ensure the health and safety of workers and their families

  • Ensure that workers are properly following health and safety procedures 


Essentially it means that a group of highly-trained, certified professional are able to prevent, investigate and address work and community safety issues so that you can live a longer, healthier life.  Specifically, industrial hygienists are focused on

  • Chemical, Biological, Physical and Other Hazardous Agent Exposure

  • Emergency Response Planning

  • Community Impact and Awareness

  • Workplace Conditions / Occupational Safety

  • Detection, Planning and Control


If you own a business and your operation has the potential to expose employees or subcontractors or neighbors to possible health hazards, you need an industrial hygienist to reduce your risk, save money and, of course, offer everyone peace of mind. If you would rather pretend that environmental, safety or health issues are not important, I suggest you purchase a pair of Teflon underwear and super-size it.

How do you feel about being called an Industrial Hygienist? What would be an improved or more descriptive job title?
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Topics: Emilcott, indoor air quality, health and safety, General Industry H&S, Construction H&S, Emergency Response, H&S Training, Hazardous Waste Management, Compliance, worker safety, Lab Safety & Electrical, Fire Safety, Public Safety, Working Green

The Regulators Awake: Proposed Changes to the OSHA Hazard Communication Standard

Posted by Shivi Kakar

Oct 13, 2009 6:50:04 AM

Paula Kaufmann, CIH
Both OSHA and the EPA seemed to have recently awoken from their regulatory slumber. OSHA has announced its first major rulemaking during the Obama administration with a proposed change to the agency’s Hazard Communication (HazCom) Standard.  The existing OSHA HazCom Standard provides workers with the right to know the hazards and identities of the chemicals they are exposed to while working, as well as the measures they can take to protect themselves.  This standard was originally adopted in November 1983 and has been enhanced a few times with the latest revision in February 1994.

The proposed changes set the stage for the United States to catch up with the global community in the use of globally consistent methods for chemical hazard classification, hazard labeling, and the format of Material Safety Data Sheets (MSDS).  The proposed changes will align the HazCom Standard with the United Nations Globally Harmonized System of Classification and Labeling (GHS).  The GHS was adopted by the UN in 2003 with a goal of implementation in 2008.   Most multinational companies have been following both the global system and the current OSHA Hazard Communication Program in recent years.  The US Department of Transportation has already modified the DOT requirements to make them consistent with international UN transportation requirements and the GHS.  Now it is time for OSHA.

The proposed changes will significantly improve the quality and consistency of information provided to workers, employers and chemical user by having a standardized approach to identifying the hazard, labeling the hazard on containers and equipment, and documentation of the hazard on a MSDS.  The most pronounced change that chemical purchasers and workers will see is a consistent hazard warning statements and warnings (including pictograms) along with MSDSs will always have the same information located in the same place.  These changes are critical not only for everyday users of the chemicals but also emergency responders and medical personnel.

However, the changes won’t be required next week and probably not even next year.  The process for moving through a major revision to an established regulation can be long and loud (with input from all vantages points on the changes).  OSHA took the first step of this process in September 2006 with an “Advance Notice of Proposed Rulemaking” (ANPR).  The recent step, in September 2009, is detailing the changes to HazCom with the publishing of a “Notice of Proposed Rulemaking” (NPRM). Next is the comment period (90 days – December 29, 2009) and then public hearings scheduled for early 2010.  OSHA will then draft a Proposed Standard which will have to be reviewed by the Office of Management and Budget and will consult with the Small Business Administration.  The Proposal Standard will then get published in the Federal Register, and will most likely have a comment period.  FINALLY, OSHA will incorporate changes from comments into the Final Standard, which will be published in the Federal Register with the provisions taking effect over the following months or years.

It’s a long process.  Regulators don’t have the window of time to slumber.
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Topics: Emilcott, OSHA, DOT, health and safety, General Industry H&S, Construction H&S, EPA, Emergency Response, H&S Training, Hazardous Waste Management, HazCom, worker safety, Occupational Health, Occupational Safety, MSDS, Hazard Communication Standard, Occupational Training, Safety Training in Spanish

10 Items You Need To Know About Water and Mold Damage In A Commercial Building

Posted by Shivi Kakar

Sep 1, 2009 2:37:34 AM

Mike Gfroehrer
1. The uncontrolled release of water may result in mold (fungi) growth in a previously non-water damaged area of a building if the water release is not adequately addressed within 48 hours of its occurrence. In addition to mold growth, water damaged can result in structural damage and support the proliferation of other types of biological organisms including dust mites, cockroaches, rodents, algae, and/or bacteria.

2. The uncontrolled release of water in a building with a history of water damage may cause dormant mold colonies from prior water releases to become active in less than 48 hours.

3. One of the most important factors in effectively preventing or controlling mold growth inside a commercial building is to have a written Water Response Plan in place before an uncontrolled release of water occurs.

4. An effective Water Response Plan will include provisions to immediately stop the uncontrolled release of water and prevent its’ reoccurrence.

5. An effective Water Response Plan will include provisions to immediately start removing the water by mechanical means such as extraction with wet vacuums and the use of commercial-grade drying equipment. Areas where drywall (sheetrock) are covered by large pieces of furniture, wallpaper, or cove base/moldings may require special attention that potentially includes removal of sections of the drywall. The source of the water (domestic drinking water vs. rain penetration through the building vs. widespread flooding vs. sewage backup) will also impact the required response activity. Visible inspection, moisture meters, infrared cameras, measurement of temperature and relative humidity are all tools that that may be used to identify where water damaged materials exist.

6. Depending on the capabilities of the commercial building’s maintenance staff, the Water Response Plan should anticipate the use of outside contractors such as licensed plumbers, roofing contractors, environmental consultants, water/fire damage restoration contractors, and/or qualified mold remediation contractors. It is advisable to have an established relationship with each type of contractor in order to best control costs once the Water Response Plan requires activation.

7. The most common health effect resulting from indoor mold exposure is an aggravation of allergies and/or asthmatic conditions. Prolonged exposure may cause hypersensitivity in some individuals, resulting in these individuals experiencing a severe respiratory reaction even when very low concentrations of airborne mold are present at work or at home. The variety of responses is often seen when employees working in the same area report a wide range of individual responses when near the water damaged building materials.

8. If an uncontrolled release of water is not properly responded to mold growth will likely result. Once mold growth is suspected or confirmed a qualified individual should conduct an investigation to determine the extent of the mold growth and develop a Mold Remediation Work Plan. The Mold Remediation Work Plan should identify procedures to follow when cleaning or removing mold damaged building materials so that building occupants are protected and not adversely affected by the remediation project.

9. The Mold Remediation Work Plan must include: which building materials require removal; which building materials require cleaning and disinfection; a plan for the isolation of the work area using barriers (polyethylene sheeting) and negative air machines to control airborne dust generation; documentation of worker training in proper mold remediation work procedures; and the criteria of the Post Remediation Assessment. Simply put, spraying with bleach or covering with an anti-microbial paint is not an appropriate response where mold growth is confirmed to be present on installed building materials.

10. A Post Remediation Assessment (PRA) determines if the Mold Remediation Work Plan was successful in returning the area to non-water damaged condition. The PRA must be conducted prior to the removal of isolation barriers and should include: a visual inspection to confirm water and mold damaged has been removed and the area has been appropriately cleaned; a moisture survey, using moisture meters, to document remaining installed building materials are satisfactorily dry; and confirmation that corrective actions are in place to prevent additional water damage. Depending on the extent of the mold damage air and surface samples may be collected as part of the PRA. Whenever air or surface samples are collected a qualified individual, such as a Certified Industrial Hygienist, should be chosen to determine the sample locations and assist with the interpretation of results.
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Topics: health and safety, Construction H&S, worker safety, Occupational Health, Occupational Safety, Mold, Occupational Training, Working Green, Water Response Plan

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